Open Letter to the Florida Fish and Wildlife Conservation Commission (FWC)

July 3, 2017

FWC Commissioners and staff,

I urge FWC to continue the protection of Goliath Grouper and reject the limited take proposal.

Recently, an email from FWC staff on the potential killing of the critically endangered Goliath Grouper confirmed that FWC’s decisions to kill endangered species are not based on science. E-mails to and from FWC and NOAA are public record, so the message and email addresses are shown below accordingly.

There are three key problems with this email.

First, the science denial is stated by the Director of FWC’s Fish and Wildlife Research Institute (FWRI). The FWRI mission statement is “Through effective research and technical knowledge, we provide timely information and guidance to protect, conserve, and manage Florida’s fish and wildlife resources.” The FWRI Director is a scientist who denies science.

Second, the decision to kill or not to kill (harvest) a critically endangered species currently protected (Goliath Grouper)IS a scientific question. Only scientific research can determine whether a species that previously reached commercial extinction has recovered to the point that it can be killed again without bringing the species back into the danger zone. Therefore, prior to even proposing the harvest, a solid scientific argument must be made based on evidence. If the science does not support the harvest, then the proposal to kill should not even exist.

Third, it seems FWC staff has a short memory span, or perhaps information gets lost in an alternate universe. For years, scientists doing research on Goliath Grouper have shared the information with FWC staff (FWC scientists and commissioners), attended workshops, meetings and been available for discussions. All this research shows Goliath Groupers are highly conservation dependent, and cannot withstand exploitation.

It is clear that FWC folded to the pressure of trophy hunting groups, ignoring the best available science. In order to please a handful of people, you cheated all Floridians because wildlife is part of our country’s heritage and ill-planned and unjustified hunts risk the loss of such heritage. The bear hunters must be so proud of killing bear cubs and nursing mothers and FWC was the enabler of such wildlife crime.

Every few years, FWC proposes to open a killing season for Goliath Groupers: in 2007, 2009, 2011, 2014 and now 2017. All past proposals were finally rejected in view of the scientific evidence and stakeholder opposition. But this time is different. This time, FWC is openly ignoring science right from the start.

Who is pressuring you for such ill-planned management of an endangered species?

I bet it’s the trophy fishing lobby. They must be itching to kill a magnificent fish, just to take a picture of the dead beast and let it rot in the sun. Because Goliath Groupers have such high levels of methyl mercury they are unsafe for human consumption. You must feel so proud to be enablers again of a new wildlife crime.

But here is the beauty of reality. You can’t block the sun with one finger. You can’t ignore the scientific evidence confirming that Goliath Groupers have not recovered to pre-exploitation levels, and cannot handle fishing pressure without entering again in a spiral towards extinction. For some unknown reason, FWC continues to believe the zombie myth (because it never dies) that Goliath Groupers eat everything in the reef, so they are blamed for decreasing fish and lobster stocks. The reality is that overfishing, not Goliath Groupers, is the reason for the declines. The scientific research is in your files. Read it. Stop denying science.

Finally, to give your ill-inspired killing proposal some degree of fairness, you have organized a series of Goliath Grouper Workshops so people can provide “input on goliath grouper management, including the possibility of a limited harvest in Florida state waters”. The long list of public workshops gives the appearance of a balanced survey design to get people’s input

But when the workshop locations are plotted on a map it seems your workshop strategy is biased. Because the people who will be most negatively affected by opening a harvest on Goliath Groupers, are the people who will have the least opportunities to provide face-to-face input.

Only 20 % of the workshops (Lake Worth, Stuart and Davie) can be realistically attended by the SCUBA dive businesses that rely heavily on recreational SCUBA divers who pay big money to see the Goliath Grouper spawning aggregations in East Florida between late August and early October, just when transition between the summer and winter seasons will leave these businesses in the doldrums. Will the comments collected in the workshops have the same weight that the comments collected online? http://myfwc.com/fishing/saltwater/rulemaking/comments/

To summarize, Goliath Groupers are worth more alive than dead

Opening a fishing season (the “limited take”) will end 27 years of protection in only 4 years. In order to please trophy fishers, you risk cheating all Americans of our national treasure, because nowhere else in the world you can encounter a functional population of Goliath Groupers as in Florida. The take is not supported by scientific research. Do the right thing and stop this madness. Reject the limited take, and continue the ban on Goliath Grouper harvest.

The greatest tragedy in the Goliath Grouper story is that the institutions in charge of managing its survival can’t see beyond the “fishery” label.

Open Letter to the Florida Fish and Wildlife Conservation Commission (FWC)

February 2, 2017

FWC Commissioners,

Recently, at a Facebook post, FWC made the following statement: “all wild animals deserve respect and space”. Once again, FWC is holding a meeting to discuss whether a wild animal deserves respect and space. On February 8, 2017, FWC will review the status of Goliath Grouper and “management strategies that could be considered in the future that could potentially provide additional information about this species in Florida”. This is code for discussing a potential reopening of the fishery. The same discussion was held in 2007, 2009, 2011 and 2014, with various killing proposals. All proposals were finally rejected in view of the scientific evidence and stakeholder opposition. As a reminder, Goliath Groupers live in the slow lane, with juvenile females entering the adult population by 8 years old (close to the age of menarche in girls or age of first menstruation), and they have a maximum lifespan beyond 40 years (perhaps 60 to 100 years old). For such a long lived fish, a 2 to 3-year difference between assessments to reopen the fishery is absurd.

The greatest tragedy in the Goliath Grouper story is that the institutions in charge of managing its survival can’t see beyond the “fishery” label.

Fish are wildlife. They are not commodities. They are an integral part of marine and freshwater ecosystems. They are not numbers in stock assessment models but animals with complex life histories. We kill fish to eat them. Sometimes we kill so many of them they go extinct, or almost. We killed so many Goliath Groupers once in Florida and the Southeastern USA they reached commercial extinction. This is the reason for the 1990 state and federal moratorium on harvest.

It takes 27 years to grow a 27 year old Goliath Grouper. The obvious gets lost in our current economy ruled by quarterly profits. Such short-term approach permeates through FWC when you are pressured by the fishing lobby to “do something” about the Goliaths, and that “something” is usually understood by “we want to kill them again”, with the labels of “scientific take”, “culling”, “selected take” and various creative language.

The reason most frequently used to reopen a recreational take of Goliath Grouper is the perception that Goliath Groupers eat everything and are responsible for declining fish and lobster stocks. This is an urban legend with no connection to reality. Research done by myself and others shows that overfishing, not Goliath Groupers, is the reason for declining fish and lobster stocks. In fact, Goliath Groupers eat predators of juvenile lobsters, allowing more lobsters to grow to legal size and making more lobsters available to fishers.

Sometimes the need to “thin the herd” is also used as a reason to reopen the Goliath Grouper fishery. However, the thinning is already happening because Goliaths are killed for several reasons, from the mundane (red tides, poaching) to the exotic (death by nuclear reactor). In 2005, extensive red tides killed close to 100 adult Goliath Groupers in the west coast of Florida. This is a recovery setback because we lost individuals capable of producing the next generations. In the 2009 and 2010 winters, extreme cold water temperatures in Florida killed 90 % of juvenile Goliath Groupers living in mangrove shorelines. This is another setback because we lost fish that were unable to reproduce at all, and therefore contributed nothing to the recovery. In August 2011, over 75 adult Goliath Groupers were killed at the St. Lucie nuclear power plant in Fort Pierce, Florida. The fish were trapped in the plant’s water intake canal. This is a major manmade disaster. FWC and NOAA promised improved contingency measures, but the intake canal and the danger remains.

Poaching of Goliath Grouper exists. FWC enforcement is aware of it. We also know there’s targeted catch and release, even when it represents a violation of the ongoing moratorium, plus there is “possession” in the sense that Goliaths are held out of the water to take pictures, which eventually show in social media, in sport fishing magazines, etc. (another violation of the moratorium). We don’t know how many of the “released” Goliaths actually survive (after fighting on the line and posing for pictures while drowning).

Lastly, some fishers say they want to kill Goliath Groupers to eat them. Goliaths have such high levels of methyl mercury that they are deemed unsafe for human consumption.

What economic benefits can we get from Goliath Groupers? I’m aware these days species must pay forward for their own protection and Goliath Groupers have been doing so quietly and in abundance. Although the species has not recovered to pre-exploitation levels, enough Goliath Groupers are showing up at a few spawning aggregation sites that their presence, and the SCUBA divers that come to visit them, bring a much needed lifesaver to small businesses in Florida, between late August and early October, just when transition between the summer and winter seasons will leave these businesses in the doldrums. Here, the whole is greater than the sum of its parts, because every individual Goliath Grouper contributes to the underwater spectacle of a spawning aggregation, which is what the scuba divers pay to see. In this sense, every single Goliath Grouper is precious and has value by itself, and brings added value when forming a spawning aggregation.

A live Goliath Grouper is more valuable than a dead one. And living Goliaths will keep forming spawning aggregations and contributing to the Florida economy for as long as they live.

Killing Goliath Groupers is not supported by scientific research. Continuing their protection ensures the livelihoods of Florida businesses and workers because SCUBA divers from all over Florida, the USA and the world come here to see these spectacular gentle giants. Florida is now the only place in the world where we can find Goliath Groupers reliably in any significant numbers.

For all these reasons, I urge the FWC Commission to grant Goliath Groupers wildlife status and designate this species as a non-consumptive fish for ecotourism. Scientists from FWC and other institutions can work together to manage the species for conservation.

Briefly, Goliath groupers are not to blame for declining lobster and snapper stocks in Florida, one of the main reasons behind requests to reopen the fishery.

In my paper titled “Should the Critically Endangered Goliath grouper Epinephelus itajara be culled in Florida”, I analyzed fisheries landing data since the 1950s, diver based surveys and published dietary studies. I concluded that :

1) Goliath groupers eat invertebrates (worms, molluscs and crustaceans) and poisonous fish, not snappers and other groupers. Surprisingly, many of the prey consumed by goliath groupers are in turn predators of juvenile spiny lobster. Hence, goliath groupers are a fishers’ best friend, because through top-down predator control, goliaths could allow more juvenile lobsters to grow and become available to fishers.

2) The slow recovery of the Goliath grouper population in Florida is not the cause for declining lobster and snapper stocks in Florida. Instead, overfishing is the main cause.

3) A thriving Goliath grouper population could provide additional socio-economic benefits in ecotourism, and as a potential biocontrol agent for the invasive lionfish.

Goliath groupers are a national treasure. Florida is the only place in the world where we can encounter these gentle giants, from juveniles to adults. Florida also contains 99 % of the spawning aggregation sites known worldwide. With this study in hand, we now have a strong argument to continue protection of the Goliath grouper and dismiss any claims that the Goliaths are destroying valuable stocks of lobster, snapper and other groupers.